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The Use of Cyprus Structures in International Tax Planning

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The Use of Cyprus Structures in International Tax Planning The use of Cyprus structures in international tax planning Tax and other advantages Tax planning ideas - structures Focus Business Services - Cyprus 1 www.fbscyprus.com Terms of reference Purpose - basis of preparation - assumptions: ¾ This presentation briefly sets out a summary of the advantages / features of the Cypriot tax system (pages 4 – 24) which are of particular interest to international clients and professional colleagues, a number of tax structures (pages 25 – 36) currently being used by international clients as well as some practical structuring issues (pages 37 – 39) ¾ Used as (i) a short “pre-meeting” briefing presentation, usually sent by email, or (ii) as a presentation to be discussed during a meeting with a client or a professional colleague – intermediary or (iii) simply as a short summary for general informational purposes sent to clients or professional colleagues ¾ Intended to be short. It should only take a few minutes to read. It does not constitute advice and should not form the basis of any structuring decisions, without first obtaining proper professional advise. ¾ Useful in deciding on whether to use Cyprus legal entities in your / your clients’ tax structures Focus Business Services - Cyprus 2 www.fbscyprus.com Terms of reference Purpose – basis of preparation - assumptions: ¾ Written in a simple-to-understand language to address clients as well as professional colleagues. Overuse of technical (legal / tax) terminology is avoided ¾ Assumed throughout that the client has no income from sources within Cyprus (international client case) ¾ Assumed throughout that the ultimate beneficiaries of the structures are not resident for tax purposes in Cyprus (international client case) ¾ Only ideas are discussed (in terms of specific structures), not specific solutions which should be discussed with your designated FBS International Tax Partner/s Focus Business Services - Cyprus 3 www.fbscyprus.com Tax Advantages ¾ Lowest corporation income tax rate in the EU (10%) with a number of interesting tax structuring possibilities existing to achieve significantly lower effective rates ¾ A regime especially advantageous for holding / investment, finance and royalty routing structures ¾ Sales of securities – trading or investing in shares and other securities is exempt from all taxation in Cyprus – ideal for dealing and investment structures Focus Business Services - Cyprus 4 www.fbscyprus.com Tax Advantages ¾ Thin spreads of profit on all structures / transactions are acceptable by the Cypriot Tax Authorities (spreads on trading, interest and royalty routing transactions) ¾ Access to the EU Direct tax directives – no withholding tax on dividends, interest and royalties from EU Member States (s.t. the Directives’ conditions and local anti-avoidance legislation) ¾ Exciting tax planning potential in a number of international structures ¾ Cypriot (Cyprus-registered) Non Resident Companies are possible. Cyprus companies which are managed and controlled outside Cyprus – A very interesting structure used for zero-tax trading (but no access to double tax treaties). Exempt from tax in Cyprus. [Can also (i) obtain EU VAT number and (ii) become tax resident in any given year – to access Cyprus’s treaties - by simply altering the management and control arrangements] Focus Business Services - Cyprus 5 www.fbscyprus.com Tax Advantages ¾ A wide and in many cases extremely advantageous double tax treaty network (especially with regard to the treaties with Russia, CIS, Central and Eastern Europe and India) ¾ No exit, liquidation or net worth taxes ¾ No withholding taxes, irrespective of the status of the foreign recipient, on any form of outgoing income (dividends, interest, royalties and other payments) ¾ Cyprus is an “ideal entry and exit route” into and out of the EU in this respect (no withholding taxes) Focus Business Services - Cyprus 6 www.fbscyprus.com Tax Advantages ¾ Tax haven companies are often used “above” and “below” a Cyprus structure ¾ No capital gains taxes (only imposed when Cyprus real estate is disposed of) ¾ Exemption of foreign dividend income (participation exemption) s.t. very “easy-to-satisfy” conditions ¾ Capital duty that can easily be “structured down” to nominal levels ¾ Exemption of overseas PE profits (s.t. the same conditions as those applying to dividend income conditions) and PE loss set-off! Focus Business Services - Cyprus 7 www.fbscyprus.com Tax Advantages ¾ Shipping income as well as the emoluments of the officers or crew of a Cyprus ship are tax-free ¾ The Cyprus International Trusts Law of 1992 and the Trustees Law (modeled on the 1925 UK Trusts Law) provide a vehicle (the Cyprus International Trust) which is very useful for tax and non tax purposes. ¾ A unique and interesting feature of the Cyprus International Trust is that the client can register a Cyprus resident company to act as a trustee, settlor or beneficiary (effectively to indirectly, via the company, act as a trustee). Focus Business Services - Cyprus 8 www.fbscyprus.com Tax Advantages at a glance ¾ Unilateral credit relief ¾ Group relief for losses and unlimited loss carry forward ¾ Absence of CFC legislation ¾ Absence of Thin Capitalisation Rules ¾ No substance requirements ¾ No specific anti-avoidance provisions Focus Business Services - Cyprus 9 www.fbscyprus.com Tax Advantages ¾ Simplicity of system – not a lot of “flaws” requiring further “structuring out”. No need for complex tax structuring, leaving time for proper company administration & management ¾ Simple & tax effective exit strategies available ¾ Possibility to elect any functional currency ¾ Stamp duty capped at low levels ¾ Easy migration of legal entities into and out of Cyprus from/to other jurisdictions Focus Business Services - Cyprus 10 www.fbscyprus.com Adoption of EU Directives into Cyprus Law [Tax Advantages] Parent-subsidiary Directive ¾ No withholding tax on the payment of dividends to any non residents ¾ Foreign dividends exempt - s.t. very “easy-to-satisfy” conditions ¾ No transitional period needed – immediate effect ¾ No minimum participation/shareholding Focus Business Services - Cyprus 11 www.fbscyprus.com Adoption of EU Directives into Cyprus Law [Tax Advantages] Parent-subsidiary Directive ¾ No minimum holding period rules ¾ Tax credit for tax withheld abroad and underlying profits tax ¾ Tax credit for underlying taxes paid by EU subsidiary or ANY lower level EU subsidiaries Focus Business Services - Cyprus 12 www.fbscyprus.com Adoption of EU Directives into Cyprus Law [Tax Advantages] Interest / Royalties Directive ¾ No withholding tax on the payment of interest to any non residents ¾ No transitional period needed – immediate effect ¾ 25% minimum participation/shareholding required in the case of royalties ¾ No minimum holding period rules ¾ Interest taxed depending on nature Focus Business Services - Cyprus 13 www.fbscyprus.com Adoption of EU Directives into Cyprus Law [Tax Advantages] Interest / Royalties Directive ¾ Active interest income is subject to corporation tax (10%) and passive interest income at a 15% effective rate ¾ Group finance activities are deemed as active interest income and are subject to corporation tax (10%) ¾ Royalties are subject to corporation tax (10%) ¾ Tax credit for tax withheld abroad Focus Business Services - Cyprus 14 www.fbscyprus.com Adoption of EU Directives into Cyprus Law [Tax Advantages at a glance] Merger Directive ¾ Applies to any reorganisation - Merger - Division (incl. partial division) - Transfer of assets - Exchange of shares ¾ Involves companies resident and not resident Focus Business Services - Cyprus 15 www.fbscyprus.com Other Advantages ¾ Member of the European Union ¾ Full OECD and EU compliance ¾ A tax system that is stable (last tax reform in 2002) and “here to stay” without any further changes on the horizon ¾ Not a tax haven ¾ UK legal system (ex British Colony) ¾ Flexible and modern Legislation Focus Business Services - Cyprus 16 www.fbscyprus.com Other Advantages ¾ Excellent and mature professional and commercial infrastructure ¾ Mature financial and banking sector ¾ Investor-friendly tax authorities ¾ Low operation costs ¾ Very large expatriate community Focus Business Services - Cyprus 17 www.fbscyprus.com Definitions and tax base “Tax Residence” ¾ When applied to a company, means one whose management and control is exercised in Cyprus Focus Business Services - Cyprus 18 www.fbscyprus.com Definitions and tax base “Management and control” ¾ No definition exists in the law ¾ In practice, as a minimum: - the place where the majority of the members of the BOD reside (FBS can provide Cypriot directors) - the place where the majority of the board meetings take place and the significant decisions taken (a number – all, if possible - of the BOD meetings should be organised in Cyprus every year with the foreign directors flying in to attend) Focus Business Services - Cyprus 19 www.fbscyprus.com Definitions and tax base “Management and control” – cont’d ¾ BOD to be a decision making forum ¾ No dominant directors or shareholders ¾ No general powers of attorney (based on case law amount to “migration of control” as well as posing a risk of establishing a dependant agent permanent establishment in the country of the attorney Focus Business Services - Cyprus 20 www.fbscyprus.com Definitions and tax base “Management and control” – cont’d ¾ Bear in mind that the challenge here on the tax residence is going to come from outside Cyprus, so “reinforcing” tax residence by establishing proper management
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